June 2014 Update on the Tax Division’s Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks

On Aug. 29, 2013, the Department of Justice released its Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks. The Program required Swiss banks to submit letters of intent to the Tax Division no later than Dec. 31, 2013, requesting consideration for a non-prosecution agreement. In January 2014, Assistant Attorney General Kathryn Keneally of the Tax Division announced that the Tax Division had received 106 letters of intent.
The Tax Division has been engaged in extensive discussions with those institutions. Based on these discussions, the Tax Division has announced additional comments regarding the Program as well as extensions of certain Program deadlines.
The Tax Division has published on its website a document that contains these additional comments.

The following post appears courtesy of the Tax Division On Aug. 29, Deputy Attorney General James M. Cole and Ambassador Manuel Sager of Switzerland signed a joint statement announcing the program for non-prosecution agreements or non-target letters for Swiss banks (the program). For eligible Swiss banks that want to seek non-prosecution agreements to resolve past cross-border criminal tax violations, the Dec. 31, 2013, deadline to enter the program is now less than two months away. At its core...

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